CINCO (collectively with its affiliates and subsidiaries, as relevant, hereinafter referred to as “CINCO”, “we”, “us”) and its Client respect and are committed to supporting rights to privacy and understanding the importance of protecting personal information and complying with applicable data protection laws.

This Privacy Policy (“policy”) outlines how we collect, use, share, and safeguard your Personal Data (as defined below) when you interact with us, including through our websites/platform (including our AI Experience Platform) (collectively “Platform”), mobile applications, products, and services (collectively, “Services”).

This policy applies to all users globally and applies to our affiliates and subsidiaries to the extent they have access to your Personal Data.

This policy provides information on the collection, use, and sharing of your Personal Data when CINCO acts, depending on the circumstances, either as (i) a data controller (meaning where CINCO controls how and why your personal information is processed applicable only on Cinco’s own brand platforms like Cinco’s website and Cinco AI Experience) or (ii) a data processor (when processing your Personal Data on behalf of its clients who are the data controllers applicable when the experience is own by our Clients), unless otherwise provided in a separate agreement or mandated by any applicable law.

For the avoidance of doubt, when CINCO’s corporate clients license from CINCO the use of the Platform for the development of their respective businesses, they shall be deemed to be the data controller (and CINCO the data processor), with respect to the personal data they are collecting from individuals using the Platform.

Our Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies or their processing of your data (including Personal Data). We do not control these third-party websites, and we encourage you to read the privacy policy of every website you connect to in order to understand your rights and obligations.

By accessing and/or using our Services, you agree to the terms of this policy.

Definitions

For the purposes of this policy:

 

  1. What Personal Data do we collect?

    We may collect the following types of Personal Data from You:

    • Contact Information: Name, email address, phone number, and postal address.
    • Technical Data: IP address, browser type, device information, and usage data (e.g., interaction with our websites/platforms).
    • Marketing Data: Your preferences in receiving marketing from us and your communication preferences.
    • Transaction Data: Information related to your purchases, orders, or subscriptions.
    • Sensitive Data: We do not typically collect sensitive data such as race, religion, or health-related information unless explicitly provided by You for a specific purpose, and only where lawful.

  2. How do we collect your Personal Data

    We collect Personal Data in several ways, including:

    • Directly from You: When You provide your data through emails, voice, when completing forms and surveys from our Platform, or when you are creating an account with us. We may also collect information You have provided to us at meetings, exhibitions, and events (both physical and digital). Your employer, as our client or partner, may provide your contact information to us where you have consented to this, and as required to provide You our products and services.
    • Automatically: When You interact with our website or download mobile and desktop app from our Platform through the use of cookies, server logs, and similar technologies.
    • Third Parties: We may collect your Personal Data from third parties, such as marketing partners or publicly available sources, where legally permitted. For example, we may collect and receive Personal Data about You from companies that purchase or distribute CINCO’s products by way of co-branded or private/white-labeled websites/platforms.

  3. How We Use Your Data

    We use your Personal Data for the following purposes:

    • Service Delivery: To provide and maintain our Services, including in order to operate fully white-labeled solutions for our corporate clients, agencies, and other commercial third parties, and for customer support.
    • Marketing: To send You relevant marketing communications, offers, and promotions, in compliance with your preferences and applicable law.
    • Analytics: To analyze user behavior, improve our website, and monitor usage trends.
    • Legal Compliance: To comply with legal obligations and protect our rights.

  4. Choice/opting out of marketing

    We offer You the choice of receiving different types of communications and information related to our Services. You may subscribe to e-newsletters or other publications; You may also elect to receive marketing communications and other special offers from us via email. If at any time You would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism in all our marketing communications, or You may contact us directly at the email provided below (under Section 18 – How to Contact Us).

    Note that if You opt out of marketing, You may still receive service-related and market research messages from us (and You may still receive marketing messages for a short period after opting out while we update our records).

  5. API Services

    For certain limited services provided by CINCO, we use third-party API Services such as the Open AI API, the YouTube API, or the Google API. Such third-party API services used in CINCO products only capture data You designate CINCO to access on third-party platforms. Such data may include your content stored on third-party sites, associated metadata, and account information related to those third-party sites. Data collected by CINCO using third-party API services may be used to archive content and certain associated metadata uploaded to those third-party sites by You.

    Additionally, such data may be used by CINCO as part of an authentication and authorization framework to access your data on third-party sites. Third-party email, social media, and other communication services are not offered, controlled, or provided by CINCO. CINCO is not responsible for how a third party transmits, accesses, processes, stores, uses, or provides your data (including Personal Data) to CINCO. In addition, such third-party services are subject to the terms and conditions of such third-party providers, including Google's privacy policy and/or the YouTube terms of service if applicable.

  6. Artificial Intelligence

    CINCO uses artificial intelligence (“AI”) technology to enhance the functioning and quality of the Platform and the Services it provides to You. We do not use your Personal Data to train the algorithms in any AI technology we use in connection with the provision of the Platform and the Services.

    We are committed to ensuring that the use of AI systems in our Platform and Services complies with applicable data protection laws

    Should we need to use your Personal Data in the future for training our algorithms in any AI technology, we will do so only with your explicit consent (when legally required).

    However, CINCO reserves the right to use your Usage Data (other than Personal Data) for machine learning and analytics services, and otherwise training AI algorithms, provided that such Usage Data is and remains anonymized and aggregated.

  7. Legal Basis for Processing Personal Information

    We process your Personal Data on one or more of the following lawful grounds:

    • Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party. For example, to manage your account with us, to provide the support You have asked for, and to respond to questions You may have when using our services. We may also be requested by our corporate clients who have purchased the use of our solutions on a white-labeled basis (such as a website/platform created by CINCO for them) to process your Personal Data under their instructions.
    • Legitimate Interests: Where it is necessary for our legitimate business interests, except where those interests are overridden by your privacy rights. For example, to develop and improve our Services, monitor their usage, analyze how our Services are being used, how users are interacting with the Services, prevent possible wrongdoing in connection with the use of our Services, and carry out satisfaction surveys.
    • Consent: Where we have obtained your explicit consent (e.g., for marketing communications when legally required).
    • Legal Obligation: To comply with a legal obligation (e.g., tax reporting, legal claims)

  8. Data Sharing and Disclosure

    We may share your Personal Data with the following parties:

    • Service Providers: We engage third-party service providers to help with our operations, such as hosting, data analytics, payment processing, or marketing services.
    • Affiliates and Business Partners: We may share data with our affiliated companies and trusted partners for business purposes.
    • Legal Compliance: We may disclose your personal information if required by law or in response to valid requests by public authorities (e.g., court orders, government agencies).

    Where third parties are performing processing on our behalf, we will require these organizations to adopt adequate technical and organizational security measures to protect Personal Data and to ensure the processing of Personal Data is only performed as instructed by us and for no other purposes and in compliance with applicable data protection laws.

    We do not sell your Personal Data to third parties.

  9. International Data Transfers

    As a global company, your Personal Data may be processed outside the country of your residence by us or our affiliates, partners, service providers, or agents working on our behalf. The transfer to other countries by CINCO and its affiliates shall be in accordance with applicable data protection laws, which may include, on the basis of an EU adequacy decision or other appropriate safeguards. Appropriate safeguards may include: CINCO and third parties entering into the Model Clauses approved by the relevant authorities (i.e., European Commission, Information Commissioner’s Office, Federal Data Protection, and Information Commissioner, etc.) or relying on any approved alternative mechanism to ensure lawful transfer and protection of Personal Data in accordance with applicable data protection law in the jurisdiction where data may be processed.

  10. Data Retention

    Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or performing any obligation to You or any regulatory authority. Under some circumstances, we may anonymize your Personal Data so that it can no longer be identified or associated with You. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without either further notice to You or requiring your consent.

    Once your Personal Data is no longer needed, we will securely delete or anonymize it.

  11. Your Privacy Rights

    If your Personal Data has been submitted to us by or on behalf of a corporate client of our Services who is the controller of that Personal Data and we are the processor, you will need to contact them directly if you wish to exercise any rights you may have under applicable data protection laws. If you make your request to us, we will need the name of the client who submitted your Personal Data to us, and we will refer it on to them.

    Your local applicable law may provide certain rights regarding the collection, use, and sharing of your Personal Data. As a minimum standard, we aim to enable all individuals to exercise the privacy rights set out below, but please note that these rights and the conditions for exercising and processing them (including response times) may vary depending on the jurisdiction in which you reside.

    Additional Information: Where You have GDPR-based Privacy Rights

    Under the European Union (EU) data protection laws, and notably the GDPR, where these apply to You (notably, based on your being resident in an EU country), You have rights we need to make You aware of. The rights available to You depend on our reason for processing your Personal Data:

    • Your right of access. This enables You to receive a copy of the Personal Data we hold about you. This right always applies. There are some exemptions, which means You may not always receive all the information we process.
    • Your right to rectification. You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete the Personal Data you think is incomplete. This right always applies.
    • Your right to erasure. You have the right to ask us to erase your Personal Data in certain circumstances.
    • Your right to restriction of processing. You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
    • Your right to object to processing. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes You want to object to our processing of your Personal Data on this ground. You also have the right to object when we are processing your Personal Data for direct marketing purposes.
    • Your right to data portability. This only applies to the Personal Data you have given us. You have the right to ask that we transfer the Personal Data you gave us from one organization to another selected by you or give it to You, and in a structured, commonly used, machine-readable format. The right only applies if we are processing Personal Data based on your consent or under, or are in discussions with You about entering into a contract, and the processing is automated.

    To exercise any of these rights where applicable, please contact us at the addresses indicated in Section 17 (How to Contact Us) below.

  12. Cookies and Tracking Technologies

    We use cookies and similar tracking technologies to enhance your user experience, analyze trends, and gather information about how our Platform and relevant Services are used. You can control the use of cookies through your browser settings.

    For more details, please refer to our Cookie Policy set out below.

  13. Data Security

    We take adequate measures to protect your Personal Data from unauthorized access, alteration, or destruction (both online and offline). These include encryption, secure servers, and access controls. However, no security system is completely impenetrable, and we cannot guarantee the absolute security of your Personal Data. Furthermore, You should note that when we host a Platform on behalf of a client, and such client acts as a data controller (and we are a processor), such data will be returned to the applicable client at the end of our relationship with that client or for other lawful reasons.

  14. California: Your Rights under the CCPA (where applicable to You)

    Under this policy, and by law, if You are a resident of California, You have the following data privacy rights in respect of a controller of relevant Personal Data (whether CINCO or our corporate client for whom we are operating the Platform on a white-labeled basis):

    • The right to notice. You must be properly notified of which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
    • The right to access/the right to request. The CCPA permits You to request and obtain from CINCO information regarding the disclosure of your Personal Data that has been collected in the past 12 months by CINCO or its subsidiaries to a third party for the third party's direct marketing purposes. Be aware that we are transferring your Personal Data to our client (for which we build the Experience Platform for).
    • The right to know about your Personal Data. You have the right to request and obtain from us information regarding the disclosure of the following:
      • The categories of Personal Data collected
      • The sources from which the Personal Data was collected
      • The business or commercial purpose for collecting or selling Personal Data
      • Categories of third parties with whom we share personal data
      • The specific pieces of Personal Data we collected about You
    • The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.

    Exercising Your CCPA Data Protection Rights

    In order to exercise any of your rights under the CCPA, and if You are a California resident, You can email us the details to our contact email below (Section 17 – How To Contact Us).

    We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

    Do Not Sell My Personal Data

    We do not sell personal information, but we are transferring it to our client. However, our clients and service providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

    If You wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, You may do so by following the instructions below.

    Please note that any opt-out is specific to the browser You use. You may need to opt out on every browser that you use.

    Website

    You can opt out of receiving ads that are personalized as served by our service providers by changing your preferences in our Cookie Policy. The opt-out will place a cookie on your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by your browser, You will need to opt out again.

    Mobile Devices

    Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to your interests:

    • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
    • "Limit Ad Tracking" on iOS devices

    You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

    "Do Not Track" Policy as required by the California Online Privacy Protection Act (CalOPPA)

    Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

    Your California Privacy Rights (California Business and Professions Code Section 22581):

    California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

    To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.

    Be aware that your request does not guarantee the complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

  15. Children’s Privacy

    Our Service does not address anyone under the age of 16. We do not knowingly collect Personal Data from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If We become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.

  16. Changes to This Privacy Policy

    We may update this policy from time to time to reflect changes in our practices or legal requirements. If we modify this policy, we will post the revised version here. You should review this page periodically for updates.

    If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal information, we will notify you by way of a prominent notice or pop-up on our applicable Platform.

  17. How To Contact Us

    If you have any questions or concerns about this Privacy Policy or our Personal Data processing practices, or wish to exercise a relevant data privacy right under applicable law, you can contact us at the following address: [email protected]

  18.  

COOKIE POLICY

Introduction 

In addition to any information that you choose to submit to us, we or selected third parties may use a variety of technologies that store or access information already stored on your personal computer, laptop, tablet or mobile phone (each a device) whenever you visit or interact with our website (may be referred to as “Platform” or “AI Experience”).

We use various technologies to collect and store information when you use the Platform. These may include using cookies or other tracking technologies (including web beacons) to identify your browser or device and give you a personalized experience when using our Services.

 

  1. 1. The Information Collection Technologies (Cookies/Web Beacons)

A few of the methods that may be used to store or access information already stored on your device include the following (and in the future, other technology and methods will be developed).

 

A. Cookie Type: Required Cookies (often “called “Strictly Necessary cookies”)

Description: Required cookies make it possible for you to access our Platforms, navigate within the Platforms, and access information related to your account if applicable. Each time you log into the Platforms, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow the AI Experience to uniquely identify you when you are logged into the Platforms and to process your online transactions and requests.

These cookies do not store any Personal Information.

Management Settings: Required cookies are necessary to operate the Platforms, so you can’t opt out of them.

 

B. Cookie Type: Functionality Cookies

Description: Functionality cookies allow the Platforms to remember information you have entered or preferences you select, and provide enhanced, more personal features. These cookies allow you to optimize your use of the website Platforms after logging in. These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize.

Management Settings: You can use your browser settings to opt out of functionality cookies. Note that opting out may affect the functionality of our Site or Platforms for you.

 

C. Cookie Type: Performance Cookies

Description: These cookies collect data about how visitors use the Platforms. This includes data like which pages visitors go to the most. These cookies don’t collect information that individually identifies visitors. 

The data these cookies collect is aggregated and intended to be anonymous and used to improve how the site functions and performs. 

Management Settings: You can use your browser settings to opt out of performance cookies.

 

D. Cookie Type: Targeting or Advertising Cookies

Description: The website may have third-party Service Providers track and analyze usage and volume statistical information from those who visit our Platforms. The Website sometimes uses cookies placed by its third-party Service Providers to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Platforms. The data given to the third-party service providers does not include information that identifies you specifically, but this data may be re-associated with information that identifies you specifically after the Website receives it.

Management Settings: These opt-out tools are provided by third parties, not xSpace. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

This website may also use third-party advertising networks that collect IP addresses and other data from web beacons (see below) on the Platforms, from emails, and on third-party websites. Ad networks follow your online activities over time through automated means, such as cookies and web beacons. They use this data to provide ads about products and services tailored to your interests. You may see these ads on other websites. This helps us manage and track the effectiveness of our marketing. Below are third parties that potentially place tracking technologies on the Platforms.

The above list of third-party Service providers that place cookies is subject to change and the above list may not include all such providers at any given time.

What’s a Web Beacon?

We may use web beacons along with cookies to gather data about the use of the Platforms and interaction with emails from CINCO (or our corporate client). Web beacons are clear electronic images that can recognize certain types of data on your computer, like cookies, when you view a particular website tied to the web beacon and a description of a website tied to the web beacon. For example, we may put web beacons in marketing emails that notify us when you click on a link in the email that directs you to the Platforms or one of its pages. We may use web beacons to operate and improve the Platforms and email communications.

 

2. Third-Party Collection of Information

We have provided you with the information above about the types of third-party information storage or gathering techniques on our website. This policy does not apply to applications (apps), technologies or sites that are owned and/or operated by other parties (such as app developers, third-party advertisers, or third-party ad servers), even if they use our technology to store or collect data. This includes third parties that embed our technology in their apps or advertisements to facilitate download tracking or advertisement serving. We do, however, work with third parties to ensure that you are provided with the necessary information and are provided with the opportunity to make your choice. The relevant third party’s terms of use, privacy policy, permissions, notices, and choices should be reviewed by you regarding their collection, storage, and sharing practices, since they may be different from ours.

 

3. What We Do With IP Addresses

When you visit the Platforms or use our products and services, like our APIs, we may collect your IP addresses to track and analyze information about the devices that are connecting to our systems and about where those devices are located. For example, we may use IP addresses to (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our websites to certain users, and, (iv) better understand how our websites are utilized and track which regions visitors to our Platforms or Customers logging into our Platforms come from. 

An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet

  1. 4. How We Treat Do Not Track Signals/California Do Not Track Disclosure

Various browsers allow a “do not track” (DNT) setting that relies on a technology known as a DNT header, which sends a signal to websites visited by the individual about the individual’s browser DNT setting. At this time, there is no general agreement on how companies like CINCO should interpret Do Not Track signals. Therefore, CINCO does not currently commit to responding to DNT signals, whether that signal is received on a computer or on a mobile device. We will make efforts to monitor developments around DNT browser technology and the implementation of a standard.

 

5. Contact Us

If you have any questions about this Cookie Policy, you can contact us by email at: [email protected].